20171129UM 1897 CUB Data Requests 1-9 to Hydro One.pdf

September 29, 2017

Re: UM 1897 – Avista and Hydro One Merger – CUB’s First Set of Data Requests to Hydro One

Enclosed please find the Oregon Citizens’ Utility Board’s (“CUB”) First Set of Data Requests to Hydro One in the above-referenced docket. Hydro One has fourteen days to respond to these
data requests. Please post responses to Huddle no later than October 13, 2017. Please note that
CUB’s data requests are continuous in nature and require the Company to update any previous
data responses as new information becomes available during the pendency of the case. In the
event any of the responses to the requests below include spreadsheets, please format the spreadsheets in electronic form with cell formulae intact. Please do not hesitate to contact CUB
with any questions.

1. Explain on what basis Hydro One and Avista chose a total Rate Credit amount of $31.50
million U.S Dollars over 10 years?
2. Beginning on line 7 of Page 13 of Thies’ Testimony, the Company states, “The
partnership of Avista and Hydro One will provide opportunities for efficiencies in the
long-term through sharing of best practices, technology and innovation. The Proposed
Transaction will provide benefits to Avista’s customers that otherwise would not occur.” Please list the technology that Hyrdo One plans on bringing to Oregon Natural Gas
Customers.

3. How will Hydro One manage Canadian Dollar and U.S. Dollar exchange rate risk?
4. Please provide a narrative explanation of the extent that Hydro One has experience
working with the Cap and Trade Program in the province of Ontario.

5. Beginning on Line 4 of Page 9 of Lopez’s Testimony, the Company states “As of June
30th, 2017, the Province owns approximately 49.9% of Hydro One’s common shares.” How much equity will the Province of Ontario own in Hydro One post-merger?

6. On Page 2 of Appendix 1 to the Application, a figure details the Post-Closing Corporate
Structure of Hydro One Limited. There are several holding corporations between Hydro
Hydro One
483 Bay Street, 8th Floor
South Tower
K&LGates
925 Fourth Avenue, Suite 2900
Seattle, WA 98104
UM 1897 CUB’s First Set of Data Requests to Hydro One | 2 P a g e
One Limited and Avista Corporation. The first holding company is referred to as Can
Sub (Ontario Corporation). What is the name of this first holding company?

7. In reference to the previous question, what types of advantage does the first holding company (Can Sub) hold to Hydro One? Does the initial Ontario Corporation provide a
reduction of risk for Hydro One?

8. Please provide the work papers and analysis that detail Hydro One’s internal valuation of
Avista.
9. What is the annual free cash flow for Hydro One for the most recent fiscal year?

Liz Jones, OSB #170349 Staff Attorney
Oregon Citizens’ Utility Board
610 SW Broadway, Ste. 400
Portland, OR 97205 T. 503.227.1984 x 11 F. 503.224.2596
E. [e-mail]